August 4, 2010
1 - Financial advisors already have plenty of rules and regulations, along with a plethora of inspectors from various SRO's, government, agencies, and broker-dealers, etc., each of whom tend have their own interpretation of them. Adding more rules and regs is not going protect the client who doesn't read the disclosures anyway, nor do they really understand what a fiduciary really stands for. It'll only make it more expensive for the advisor to serve the client, and it'll be the client who ends up paying.
2 - Applying simular standards and regulatory oversight for both broker-dealers and investment advisors is a great idea. Just make sure that the inspectors understand the differences in operation and the varying scope by which advisors or broker-dealer represetatives may serve clients, and that dual registered advisors may have certain redundantcies built in to one side which should suffice. A single set of standards with metrics by which to measure true compliance would be welcomed. Not more rules just better application of what already exists.
3 - Training and experience of the various inspectors should be better regulated. All too often I find them inadequately equipped to perform anything more than counting up meaningless shortcomings lacking at internal department coordination and understanding between brokerage businsess, insurance business, and advisory business devoid of a focus on what's really important and how to look for it and at odds another regulator's rules and their enforcement. (In other words, I will refuse to revert back to state registration under the inept and unprofessional oversight of the Commonwealth of Virginia, so help me God).
4 - Good standardized compliance practices (like those in already in effect) applied by advisors, along with standardized metrics applied by well-trained inspectors would be good so, more is not going to be bettter, just more expensive.